1. Industrial Footprint Project
Regulatory Performance Advisors, November 13, 2003
Industrial Footprint Project
Carol Kraege
Washington State Department of Ecology
I’m the manager of the Industrial Section- a group of 25 people with multi-media responsibility. We regulate the largest industries in the state- pulp and paper/ aluminum smelting/ oil refining. We do all the environmental regulation – air/water/waste/cleanup and all the functions are done by one engineer- permitting / inspections/ enforcement. In addition, I’ve recently taken on management of the state’s PBT program, which is just in its infancy, but was put in my group because it is a multi-media activity as well. This project came out of our experiences in the cross program world

2. Regulatory Performance Advisors, November 13, 2003
What’s a footprint?
A holistic measure of the impacts of a facility
Social
Economic
Environmental
Conceptually, not very complicated- in practice, we expect it to be a little more difficult

3. Regulatory Performance Advisors, November 13, 2003
Why a footprint?
The current regulatory system often frustrates progress
High cost, often for small return
Global and local problems persist
Permits become a battlefield
Priorities are driven by piecemeal laws, not environmental needs
Important concerns aren’t addressed; e.g. global warming, resource depletion, energy and water conservation, habitat/ species loss, local issues such as odors
No framework for prioritizing among issues, impacts
Much of focus is on administrative matters
Rules are prescriptive, lack flexibility

4. Regulatory Performance Advisors, November 13, 2003
With Limited Resources…
Footprint Approach
Traditional Regulation
Start with Footprint Measurement
Starts with Laws, Standards
What a facility's “footprint” encompasses and how to measure it are not simple questions, as we’ll see later.
We started out with the idea that it might be measured much like sticking a thermometer in it – this idea has been used in other contexts, e.g. to quantify the footprint of nations or other human populations on the earth’s resources and waste assimilative capacity, with many simplifying assumptions. To attempt this for an industrial facility, where we might be concerned with such disparate types of impacts as cancer risks from air emissions to odors, to greenhouse gas emissions, so many assumptions would have to be made, and subjective judgments as to their relative significance, that it became clear that a participatory, consensus-driven process is needed to address them.
Results:
Compliance, and Maintenance +/- of Facilities Regulated Environmental Footprint
Hypothesis:
Greater Reduction in Facility’s Overall Environmental Footprint is Possible

5. Regulatory Performance Advisors, November 13, 2003
If you want to reduce the footprint,
which do you measure?
Regulations
Laws
OR?
Here
Here’s another way of looking at it.
“What You Measure is
What You Get”
Regulations
Laws

6. Facility Reporting Project
Regulatory Performance Advisors, November 13, 2003
Facility Reporting Project
The Facility Reporting Project (FRP) is a multi-stakeholder initiative to develop a generally-accepted facility-level economic, environmental and social sustainability reporting framework.
We looked at a lot of multi-media measurement schemes and settled on the FRP
We are participating in the pilot of the FRP and have access to Ceres for help with stakeholders, etc.
FRP was designed for facilities to report, so we are using the indicators for a different purpose, but we believe it will serve our purposes well, plus it’s being vetted by industry now, so it helps with credibility.

7. What should be measured?
Economic Indicators
Purchase of local goods
Total payroll
Taxes and subsidies
Donations
Local infrastructure investment

8. What should be measured?
Social Indicators
Labor practices and decent work
Employment
Management relations
Health and safety
Training and education
Diversity and opportunity
Human Rights
Society

9. What should be measured?
Environmental Indicators
Materials
Energy
Water
Biodiversity and natural habitats
Emissions, effluents and waste
Compliance
Nuisance and quality of life

10. How will we get the data? Start with data we already have
Other publicly available data
Data directly from facilities
Use grant funding for a contractor to assist in data collection and analysis

11. How would a footprint approach work ?
Collaborate with stakeholders
Choose indicators
Measure industry’s footprint
Use the measurement to drive priorities, actions

12. How can the footprint be used?
Provide a performance measurement tool for individual facilities
Provide a baseline for sectors
Provide a basis of comparison between facilities
Assist regulatory agencies in prioritizing work
Serve as a building block to a more effective regulatory framework

13. Short term goals
Find out if the process of developing agreed upon indicators leads to a credible footprint
Find out if footprint measurement tells us more than we knew before
Find out if footprint measurement makes priority setting easier
Find out if footprint measurement is sensitive enough to measure progress

14. Possible benefits for industry
Regulatory Performance Advisors, November 13, 2003
Possible benefits for industry
Public and peer recognition
More flexibility to accommodate changes
Reduced administrative burden in non-target areas in exchange for better-than-required performance in target areas.
Increased competitiveness and viability
Improved relations with stakeholders
There’s a lot of work to be done in this arena, we have been focused on figuring out how to do the measurement. To get companies to share data, we will…. Develop a stakeholder involvement plan

15. Possible Benefits to Regulators
Better Environmental Results
Conserve valuable resources
More responsive process
Address issues of concern to community, workers, interest groups, etc.
Make industry, community more sustainable

16. Possible Benefits to Communities
Save local jobs
Keep local economy strong
Reduce confrontation, costly appeals
Get things done

17. Stakeholder Involvement
Local communities
Input regarding selection of indicators
Input regarding priorities
Education about the mill
Facilities
Focus on pulp and paper industry
Pursue consensus regarding indicators
Education about community needs

18. Regulatory Performance Advisors, November 13, 2003
Success Measures
Credible measure
Broad
Robust
Cost-effective
Safe
Transferable
Informative

19. Success Measures Substantial environmental improvement
Facility performance does not regress in any area
Progress is measurable
Good faith/partnering is essential

20. Regulatory Performance Advisors, November 13, 2003
Example
A couple examples of what it might look like in visual summary form:
Profile aggregates impacts of similar types, e.g. several types of greenhouse gasses. Relative heights aren’t comparable but facilities can be compared with each other.

21. Some Likely Concerns Current Laws & Rules won’t go away
EPA won’t allow it
We’ll get sued
We’ll lose our ability to sue
It’ll cost too much
It’ll allow industry to back off on protections
It’ll start a bad precedent
Congress and the legislature already set policy
Ecology has no business…

22. Long term possibilities
Develop a single permit for air, water and waste
Identify facility specific priorities
Consider community needs
Consider facility opportunities
Develop incentives
Pursue changes in state and federal laws to improve flexibility and performance